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TMI Blog2023 (9) TMI 425X X X X Extracts X X X X X X X X Extracts X X X X ..... PER SANJAY GARG, JUDICIAL MEMBER: The present appeal has been preferred by the assessee against the order dated 21.11.2022 of the National Faceless Appeal Centre (hereinafter referred to as the 'CIT(A)') passed u/s 250 of the Income Tax Act (hereinafter referred to as the 'Act'). 2. The sole issue involved in this appeal is as to whether Tax at Source (TDS) was liable to be deducted u/s 194 of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Tribunal in Income-tax Appeal No. 808/PUN/2016. 3. This Appeal pertains to the Assessment Year is 2013-14. 4. The Appellant-Revenue has raised the following questions as a substantial questions of law :- "(a) Whether on the facts and circumstances of the case and in law, the Hon'ble Income Tax Appellate Tribunal erred in holding the discount given by the assessee to its distributors on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d therefore not liable for deduction of the TDS under section 194H. The Tribunal noted that there was no decision of this Court on this issue on that date. 6. Learned counsel for the parties have tendered the copy of the order passed in subsequently in the case of Pr. CIT v. Reliance Communications Infrastructure Ltd., Income-tax Appeal No. 702 of 2017, where same issue arose for the considerati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed above, the same principle would apply in the present case. Therefore, the questions of law as proposed do not give any rise to substantial question of law. The Appeal is disposed of." 4. The case of the assessee is on better footing. In the above referred to the decision, Idea Cellular Company owned the sim cards which were further sold to the distributors. However, in the case in hand, the as ..... X X X X Extracts X X X X X X X X Extracts X X X X
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